The SEC Whistleblower Program

Published by The Click Lab Agency LLC. Last reviewed September 2026. Not legal advice.

The SEC Whistleblower Program was created by the Dodd-Frank Act of 2010 and is codified at 15 U.S.C. §78u-6. It is the largest federal whistleblower program by both submissions and dollars awarded. Since it began paying awards in 2012, the SEC Office of the Whistleblower has reported more than $2 billion paid to more than 400 people. The figures move; the office's own reports are the source, and a later report controls if this sentence is behind. What follows is how a tip actually travels, from the form to the order.

What the Program Covers

The program covers violations of the federal securities laws, which include: accounting fraud and financial statement manipulation (artificially inflated revenues, understated liabilities, improper revenue recognition, off-balance-sheet schemes); insider trading by corporate insiders, analysts, or their tippees; market manipulation including spoofing, layering, pump-and-dump schemes, and wash trading; Foreign Corrupt Practices Act violations, including bribes to foreign officials by U.S. issuers or their agents (15 U.S.C. §78dd-1); Ponzi schemes and investment adviser fraud (misappropriating client funds, undisclosed conflicts of interest, false performance records); offering fraud in connection with the unregistered or fraudulent sale of securities; broker-dealer regulatory violations; and failures by registered entities (investment companies, advisers, broker-dealers) to maintain required compliance systems or disclosures. That list is illustrative. The boundary is the federal securities laws, not a closed catalog of schemes.

How to Submit a Tip

Tips are submitted using Form TCR (Tip, Complaint, or Referral) through the SEC's online reporting system at sec.gov/whistleblower. The TCR requires a description of the potential violation, the identities of the individuals and entities involved, and supporting documentation where available. Crucially, a TCR submission establishes your submission date — which determines your priority relative to other whistleblowers who submit information about the same violation. The submission date matters because the SEC generally pays only one award per enforcement action, and earlier submitters have priority when multiple whistleblowers provide information about the same scheme.

You can submit a TCR before every document is assembled and send further material to the SEC afterward, tied to the same tip. What preserves eligibility is following the SEC's procedures, not sending a complete case file on day one. 17 C.F.R. §240.21F-2(b) conditions an award on compliance with Rules 21F-4, 21F-8, and 21F-9. A later message to this website is not a supplement. Only a submission to the Commission is.

Anonymous Submission

You can submit a TCR anonymously if you are represented by a licensed attorney. The attorney submits the form on your behalf, identifying themselves but not disclosing your identity to the SEC. Your anonymity is maintained throughout the investigation. Before an award can be paid, you must disclose your identity to the SEC — but the SEC keeps that disclosure confidential from the public, from the media, and from the company being investigated. Anonymous submission is strongly recommended for current employees who fear retaliation, because it allows you to preserve anti-retaliation legal protections (which require reporting to the SEC) while maintaining some protection from immediate exposure. An experienced whistleblower attorney can manage the anonymous submission process.

What Makes a Strong Tip

The SEC's award rules at 17 C.F.R. §240.21F-6 identify the characteristics of tips that support higher awards. A strong tip is: specific (naming specific individuals, describing specific transactions, citing specific dates and amounts rather than general allegations); credible (supported by documentary evidence — emails, financial records, trading data, contracts — not just the whistleblower's verbal account); original (not duplicating what the SEC already knows from other sources or from public disclosures); and causal (providing information that actually prompted or materially advanced the investigation, not just confirming what investigators already suspected). Vague tips alleging general misconduct without specific facts or documentation are less likely to generate enforcement actions and receive lower award percentages when they do.

The Award Determination Process

After an enforcement action concludes and sanctions are collected, the SEC opens the award determination process. Eligible whistleblowers who submitted relevant TCRs are notified. They receive a "Notice of Eligibility" confirming they are in the pool of potential awardees. The SEC staff then prepares a "Preliminary Determination" setting the proposed award percentage and amount, which is served on the whistleblower. The whistleblower can appeal the preliminary determination to the SEC's Claims Review Staff. After that process, the Commission issues a "Final Order" that is the legal determination of the award. Final orders are publicly announced but do not identify the whistleblower. Final orders can be appealed to a federal circuit court of appeals.

Anti-Retaliation Protections

Dodd-Frank §21F(h)(1)(A) prohibits an employer from discharging, demoting, suspending, harassing, or otherwise discriminating against an employee in the terms and conditions of employment for providing information to the SEC, for initiating, testifying in, or assisting in an SEC investigation or proceeding, or for making disclosures required or protected under the Sarbanes-Oxley Act, the Exchange Act, or other laws within the SEC's jurisdiction. Remedies include reinstatement, twice the back pay otherwise owed, with interest, and litigation costs, expert fees, and reasonable attorney fees. The timing rule is in §78u-6(h)(1)(B)(iii): an action may not be brought more than six years after the violation, or more than three years after the employee knew or reasonably should have known the material facts, and in no event more than ten years after the violation. Read the subsection before you count a deadline. This sentence is not that count.

The limit that matters in practice comes from Digital Realty Trust, Inc. v. Somers, 583 U.S. 149 (2018). Dodd-Frank's anti-retaliation provision requires a report to the SEC. An employee who reports only through internal compliance, and never to the Commission, is outside §21F(h). Sarbanes-Oxley §806, 18 U.S.C. §1514A, can still cover an internal report, with different remedies, a different forum, and a much shorter clock. Which report to make, and in which order, changes the legal protection. This page can name the two statutes. It cannot choose between them for a particular employee.

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